HomeMy WebLinkAbout93-004 GarnerDear Mr. Garner:
I. ISSUE:
( ? r y . , j �Y
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: James M. Howley, Chair
Daneen E. Reese, Vice Chair
Dennis C. Harrington
Roy W. Wilt
Austin M. Lee
Allan M. Kluger
Joseph W. Marshall, III
DATE DECIDED: June 28, 1993
DATE MAILED: July 7, 1993
Charles D. Garner, Jr., Esquire
Reynier, Crocker, Allebach & Reber, P.C.
424 King Street
P.O. Box 777
Pottstown, PA 19464
93 -004
Re: Conflict, Public Official, Supervisor, Second Class Township,
Three - Member Board, Development, Section 3(j), Motion, Second,
Opposing Views, Deadlock, Absence, Meeting, Vote, Surety
Bonds, Business with which Associated, Zoning Change.
This Opinion is issued in response to your letter of request
dated April 13, 1993.
1. Whether the Public Official and Employee Ethics law imposes
any prohibition or restrictions upon a second class township
supervisor from participating on a development project and
zoning change when the developer utilizes a consulting firm
for certain project services which consulting firm in turn may
utilize the services of a business with which the supervisor
is associated.
2. Whether under Section 3(j) of the Public Official and Employee
Ethics Law a supervisor of a three- member board in a second
class township may second a motion even if he has a conflict
Charles D. Garner, Jr., Esquire
July 7, 1993
Page 2
when the remaining two supervisors have opposing views or when
one of the remaining two members is absent from the meeting.
II. FACTUAL BASIS FOR DETERMINATION:
As Solicitor for Limerick Township, you have been instructed
by Township Supervisor David Akers to request an advisory from the
State Ethics Commission with regard to a potential conflict which
has arisen in Limerick Township, a Second Class Township with a
three - member Board of Supervisors. Your inquiry relates to Mr.
Akers' ability to participate in votes relating to a certain
commercial development in Limerick Township.
In or about the middle of 1992, Windon Development Associates
filed a land development plan with Limerick Township to construct
a commercial development consisting of retail stores and office
buildings. Windon then hired International Management Consultants,
Inc. (IMC) to do certain preconstruction services on the project.
Presently, Supervisor Akers is employed by the Reliance Insurance
Company which provides surety bonds for IMC. Mr. Akers is a
salaried employee in the position of Bond Manager and receives no
additional compensation from surety bonds executed on behalf of
IMC. At this stage of the development, it is impossible to
determine if this project will ever be bonded. You have submitted
a copy of a written statement issued by Supervisor Akers to the
Township Secretary at the April 6, 1993 meeting of the Supervisors,
which document is incorporated herein by reference.
The time is quickly approaching when Windon Development will
need the necessary approvals of Limerick Township for both the
development plan and a minor zoning change. Since it appears that
the other two Supervisors acting on the plan have opposing views
concerning the benefit of this plan to the community, it is
entirely likely that if the matter were voted upon, the outcome of
the vote would be a tie. Furthermore, if Mr. Akers is not
permitted to participate in the discussion and /or voting, you are
not certain that this matter could even proceed since the motion to
approve would not be seconded by the Supervisor who opposes the
plan.
A similar scenario arises due to the fact that the Supervisor
who ostensibly opposes the plan travels at length and at times is
unable to attend meetings of the Board of Supervisors. If Mr.
Akers must abstain from participating in the discussions on the
plan, the problem again arises that the motion can never be
properly seconded to place the matter before the Board for a vote.
You specifically ask what, if any, role Mr. Akers may have in
this process. You believe that in accord with Section 3(j) of the
Ethics Law, Mr. Akers may break a tie in a 1 -1 vote after
Charles D. Garner, Jr., Esquire
July 7, 1993
Page 3
previously abstaining. However, you ask whether he may second the
motion to have the issue properly placed before the Board of
Supervisors. You further ask, in the event that only two of the
three Supervisors are present, whether Mr. Akers may second a
motion and subsequently vote to avoid the possibility of a one vote
in favor and one vote in abstention scenario which is not an
approval.
III. DISCUSSION:
As a Supervisor for Limerick Township, Mr. David Akers is a
public official as that term is defined under the Ethics Law, and
hence he is subject to the provisions of that law. 65 P.S. §402;
51 Pa. Code §11.1.
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
The following terms are defined in the Ethics Law as follows:
Section 2. Definitions.
"Conflict or conflict of interest." Use
by a public official or public employee of the
authority of his office or employment or any
confidential information received through his
holding public office or employment for the
private pecuniary benefit of himself, a member
of his immediate family or a business with
which he or a member of his immediate family
is associated. "Conflict" or "conflict of
interest" does not include an action having a
de minimis economic impact or which affects to
the same degree a class consisting of the
general public or a subclass consisting of an
industry, occupation or other group which
includes the public official or public
employee, a member of his immediate family or
a business with which he or a member of his
immediate family is associated.
"Authority of office or employment." The
actual power provided by law, the exercise of
which is necessary to the performance of
duties and responsibilities unique to a
Charles D. Garner, Jr., Esquire
July 7, 1993
Page 4
particular public office or position of public
employment.
"Business with which he is associated."
Any business in which the person or a member
of the person's immediate family is a
director, officer, owner, employee or has a
financial interest.
In addition, Sections 3(b) and 3(c) of the Ethics Law provide
in part that no person shall offer to a public official /employee
anything of monetary value and no public official /employee shall
solicit or accept anything of monetary value based upon the
understanding that the vote, official action, or judgement of the
public official /employee would be influenced thereby. Reference is
made to these provisions of the law not to imply that there has
been or will be any transgression thereof but merely to provide a
complete response to the question presented.
Section 3(j) of the Ethics Law provides as follows:
Section 3. Restricted activities.
(j) Where voting conflicts are not
otherwise addressed by the Constitution of
Pennsylvania or by any law, rule, regulation,
order or ordinance, the following procedure
shall be employed. Any public official or
public employee, who in the discharge of his
official duties, would be required to vote on
a matter that would result in a conflict of
interest shall abstain from voting and, prior
to the vote being taken, publicly announce and
disclose the nature of his interest as a
public record in a written memorandum filed
with the person responsible for recording the
minutes of the meeting at which the vote is
taken, provided that whenever a governing body
would be unable to take any action on a matter
before it because the number of members of the
body required to abstain from voting under the
provisions of this section makes the majority
or other legally required vote of approval
unattainable, then such members shall be
permitted to vote if disclosures are made as
otherwise provided herein. In the case of a
three - member governing body of a political
subdivision, where one member has abstained
from voting as a result of a conflict of
interest, and the remaining two members of the
Charles D. Garner, Jr., Esquire
July 7, 1993
Page 5
governing body have cast opposing votes, the
member who has abstained shall be permitted to
vote to break the tie vote if disclosure is
made as otherwise provided herein.
If a conflict exists, Section 3(j) requires the public
official /employee to abstain and to publicly disclose the
abstention and reasons for same, both orally and by filing a
written memorandum to that effect with the person recording the
minutes or supervisor.
In the event that the required abstention results in the
inability of the governmental body to take action because a
majority is unattainable due to the abstention(s) from conflicts
under the Ethics Law, then in that event participation is
permissible provided the disclosure requirements noted above are
followed. See, Mlakar, Advice 91- 523 -S.
On the question of whether Akers has a conflict, we are guided
by our ruling in Amato, Opinion 89 -002. In the cited case, we
concluded that where a public official was seeking to participate
in the award of a contract and the business with which he was
associated was two steps removed from the matter, that is, the
public official was employed by a company which sold supplies to
subcontractors who in turn did business with the contractor who bid
on the contract, no conflict would exist provided the public
official could not reasonably and legitimately anticipate that a
financial relationship would result from the award of the contract.
In the instant matter, we believe that the situation is
analogous to Amato in that Akers is employed by an insurance
company which may obtain surety bond work from a consultant
provided a surety bond is required of the consultant by the
developer. Once again, the connection between the developer and
the insurance company is attenuated by being two steps removed. We
must therefore conclude that unless Akers has a reasonable and
legitimate anticipation of a financial relationship as to his
business obtaining surety bond work, which is a factual question
that we cannot address, Akers would be permitted to participate and
vote.
As to the second question posed concerning the propriety of
Akers seconding a motion where the other two Supervisors have
opposing views or where one of the other two Supervisors is absent,
we shall address the question since it relates to future conduct.
Initially, it is true that if Akers had a conflict and the
other two Supervisors were deadlocked with Akers abstaining, Akers
could vote to break the tie provided he satisfied the disclosure
requirements of Section 3(j). eel, Bloss, Order No. 869.
Charles D. Garner, Jr., Esquire
July 7, 1993
Page 6
Turning to the situation where Akers would abstain due to a
conflict and one of the remaining two Supervisors would make a
motion, and the other Supervisor with an opposing view who had no
conflict would not second the motion, Akers could in our view
second the motion.
It is clear that seconding a motion is a use of authority of
office. Juliante, Order No. 809. Hence, if an individual has a
conflict, he could not participate, make a motion, second a motion,
or vote.
However, the General Assembly in enacting Section 3(j) would
not have allowed a public official /employee on a three member board
who has a conflict to be able to vote unless a second to the motion
could be made so that the matter would be in the posture for a
vote. Thus, we believe that since there is a need for a second to
a motion in order to make Section 3(j) of the Ethics Law operative,
the General Assembly intended as to three members boards for the
public official with a conflict to be allowed to second so that if
the other supervisors became deadlocked, the public official could
then vote provided the disclosure requirements are satisfied.
In light of the foregoing, you are advised that Section 3(j)
of the Ethics Law does allow an individual to second a motion where
a second is not forthcoming in situations where the two remaining
Supervisors have opposing views or where one of the other two
Supervisors is absent. Our ruling is expressly limited in its
application to ythree member. boards involving the questioi .7 -,.. =
presented.
Lastly, the propriety of the proposed conduct has only been
addressed under the Ethics Law; the applicability of any other
statute, code, ordinance, regulation or other code of conduct other
than the Ethics Act has not been considered in that they do not
involve an interpretation of the Ethics Law.
IV. CONCLUSION:
A supervisor of a second class township is a public official
subject to the provisions of the Ethics Law. A second class .
township supervisor may participate on a development project and
zoning change when the developer utilizes a consulting firm for
certain project services which consulting firm may in turn utilize
the services of a business with which the supervisor is associated
provided the public official may not reasonably or legitimately
anticipate a financial relationship resulting from the project.
Under Section 3(j) of the Ethics Law, a second class township
supervisor may second a motion if he has a conflict when the
remaining two supervisors have opposing views or when one of the
other two members is absent from the meeting. Lastly, the
Charles D. Garner, Jr., Esquire
July 7, 1993
Page 7
propriety of the proposed conduct has only been addressed under the
Ethics Law.
Pursuant to Section 7(10), the person who acts in good faith
on this opinion issued to him shall not be subject to criminal or
civil penalties for so acting provided the material facts are as
stated in the request.
such.
This letter is a public record and will be made available as
Finally, any person may request the Commission to reconsider
its Opinion. The reconsideration request must be received at this
Commission within fifteen days of the mailing date of this Opinion.
The person requesting reconsideration should present a detailed
explanation setting forth the reasons why the Opinion requires
reconsideration.
By the Commission,
James M. Howl
Chair
Commissioner Joseph; W. Marshall, III, concurs on the conflict issue
but dissents on _ the `issue that seconding a motion is within the
parameters of Section 3(j) of the Ethics Law.